The Whistleblower Complaint Procedure will be published on the college website, the
Public Safety and Human Resources Departments’ websites, and in the College catalog
and student handbook.

II. Reporting Fraud or Misappropriation

All college community members are encouraged to report possible fraudulent activities
or related misconduct. Reporting suspected fraudulent activities helps the college
reduce waste and abuse. Reports of alleged fraudulent activity will be treated seriously
and investigated by the college. Investigations will be conducted by the Whistleblower
Review Team (Review Team) consisting of the Vice Chancellor for Administrative Services,
the Director of Public Safety, and the Associate Vice Chancellor for Human Resources.

The college views exposing fraud and or misconduct as a service. Consistent with the
State of Michigan’s Whistleblowers’ Protection Act, good faith reporting of fraud
or misconduct will not jeopardize the employment of the reporter. To encourage the
reporting of improper activity, employees are protected from retaliation by the provisions
of state law.

How to handle suspected fraudulent or related misconduct.

Any individual suspected of fraud or related misconduct should not be confronted.
Employees should report their concern(s) through normal management reporting channels,
beginning with their immediate supervisor. Upon notification of the suspected fraud
or misconduct, the supervisor is required to report the circumstances to a member
of the Review Team. An employee can also elect to report their concerns directly to
a member of the Review Team if they find it difficult to discuss/report with their
supervisor or the suspected fraud involves the supervisor. Students and members of
the public should report their concerns directly to a member of the Review Team.

What if I want to report anonymously?

Reporting potential fraud or misuse of college resources can be done anonymously.
Every effort will be made to protect the identity of an anonymous informant. However,
the Review Team cannot guarantee confidentiality. The whistleblower’s identity may
need to be revealed if (1) identification is necessary to allow the college to investigate
or respond effectively, (2) identification is required by law; or (3) the person accused
of fraud or misconduct is entitled to the information as a part of disciplinary proceedings.
Information about the informant’s identity and the details of the complaint will be
shared on a need-to-know basis only.

What information should be provided?

Whistleblowers must provide sufficient details regarding the complaint and corroborating
evidence to justify the commencement of an investigation. An investigation of unspecified
wrongdoing or broad allegations cannot be undertaken without verifiable evidentiary
support. Since the Review Team cannot interview anonymous whistleblowers, evaluating
the credibility and completeness of the allegations may be difficult and therefore
hamper a comprehensive investigation.

III. Investigative Responsibility

The college will investigate any reported fraudulent activity or misuse of college
resources or property or violation of college policy by faculty, staff, contractors
or students. The Review Team described above is responsible for conducting and overseeing
investigations of all alleged fraudulent or dishonest conduct.

College employees may not initiate their own investigations, since such actions may
compromise ensuing reviews by the Public Safety Department or the Review Team. A member
of the Review Team shall promptly notify the college chancellor of the reported allegation(s).
The Review Team will also consult with other college staff as deemed necessary or
appropriate to pursue the investigation. Cases involving possible criminal law violations
will be turned over to the Public Safety Department.

The result of the investigation will only be disclosed to college employees having
a legitimate need to know in order to perform their job duties and responsibilities.
If the Review Team determines that fraudulent or dishonest conduct occurred, the college
will initiate disciplinary action in a manner consistent with applicable college policy
and collective bargaining agreements.

If the Review Team concludes that the allegations were unsubstantiated, an explanation
justifying its determination is provided to the whistleblower, if that person’s identity
is known.

IV. Definitions

Fraud The willful or deliberate act or failure to act with the intention to deceive
or obtain an unauthorized benefit. Such acts include, but are not limited to:

Misappropriation or misuse of college resources

Intentionally reporting inaccurate financial results

Making or altering documents or computer files with the intent to defraud

Pursuit of a benefit or advantage in violation of the college’s conflict of interest
policy

Authorizing or receiving compensation for goods not received or services not performed

Authorizing or receiving compensation for hours not worked

Destruction or disappearance of records, furniture, fixtures or equipment

Any similar or related irregularity

Waste and Abuse Although waste and abuse is not specifically defined here, the college seeks to ensure
proper utilization of its resources at all times. Accordingly, this policy includes
allegations of waste and abuse.

Whistleblower A person making a protected disclosure regarding an activity they believe is fraudulent
or dishonest. Whistleblowers may be college employees, students, vendors, contractors
or the general public. The whistleblower’s role is as a reporting party. They are
not investigators or fact finders, nor do they determine the appropriate corrective
or remedial action that may be warranted.

V. Non-fraud Irregularities

Identification or allegations of personal improprieties or irregularities, whether
moral, ethical, or behavioral, should be reported to the supervisor in the respective
department and/or to the Human Resources Department. The Review Team may be contacted
if guidance is needed to determine if an action constitutes fraud.

Allegations of student misconduct should be addressed to the Dean of Campus Affairs
on the appropriate campus for investigation.